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30 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting
Comparative
evaluation of screened
options
Screened option 1:
Screened option 2:
Red YellowGreen
Screened option 3:
Regulatory
Red YellowGreen
Screened option 4:
Regulatory
Red Yellow
Red YellowGreen
Green
Environmental
Regulatory
Regulatory
Environmental
Financial
Environmental
Environmental
Financial
Logistical Logistical
Financial
Total Logistical
Financial
Total Logistical
Total
Total
Selected options to be pursued with a more detailed analysis
Figure 5. Methodology for comparative evaluation
of the screened options.
are no obstacles, yellow means that some obstacles exist that can be remediated, and red means
that significant challenges are present and the option needs to be redrawn. Additional detail that
can be used to evaluate options against each criterion is discussed in the following sections.
3.5.1 Regulatory
What are the main regulatory elements that should be considered in the evaluation of an
alternative jet fuel project?
There are three general regulatory elements that should be considered in the evaluation of an
alternative jet fuel project. For each of these elements, this handbook indicates the main ques-
tions and associated information that the airport should consider when evaluating alternative jet
fuel projects. For more detailed information, please consult the references indicated in the fol-
lowing and in Section 6. In addition, given the complex technical issues surrounding fueling sys-
tem and airfield design, engaging an aviation consultant engineer familiar with these topics may
be advisable to assist with locating a processing facility. The main regulatory elements discussed
here are as follows:
· FAA policies and regulations
· Environmental reviews and permitting
· Energy policy
FAA policies: How do FAA policies and regulations affect airport plans to produce and
distribute alternative jet fuels?
FAA policies and regulations largely control what can or cannot be done in the airport setting.
The construction and operation of alternative jet fuel infrastructure is no exception. The FAA
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How Can Alternative Jet Fuels Be Integrated into the Airport Setting? 31
compiles and maintains a number of documents, including Advisory Circulars (ACs), Orders,
and references to other documents that should be considered when evaluating the feasibility of
placing alternative jet fuel infrastructure in the airport setting. The FAA and FAA-related docu-
ments most likely to be relevant for alternative jet fuel projects are as follows (see Section 6.1 for
full citations):
· FAA AC 150/5070-6B, Airport Master Plans
· FAA AC 150/5200-33, Hazardous Wildlife Attractants on or Near Airports
· FAA AC 150/5230-4A, Aircraft Fuel Storage, Handling, and Dispensing on Airports
· FAA AC 150/5300-13, Airport Design
· FAA Order 5050.4B, National Environmental Policy Act (NEPA) Implementing Instructions
for Airport Projects
· FAA Order 5190-6b, Appendix R, Airport Compliance Manual
· FAA Order 5190-7, Minimum Standards for Commercial Aeronautical Activities
· FAA Order 1050.1E, CHG 1, Environmental Impacts: Policies and Procedures, Paragraph 304
· Title 14 of the Code of Federal Regulations Part 77, Objections Affecting Navigable Airspace
· Title 14 of the Code of Federal Regulations Part 139, Certification of Airports
· National Fire Protection Association (NFPA) 407, Standard for Aircraft Fuel Servicing
· Best Practices for Environmental Impact Statement (EIS) Management
· Environmental Desk Reference for Airport Actions
Together, these documents point to three key items: (1) compliance with all applicable airport
design specifications, (2) an evaluation of environmental impacts, and (3) proper documentation
of proposed changes. These items are briefly discussed in the following subsections.
In addition to the FAA documents listed previously, it is important to indicate other resources
available to jet fuel handlers. For example, the American Transport Association (ATA) pub-
lishes ATA Specification 103: Standard for Jet Fuel Quality Control at Airports (ATA 2009c).
This document includes recommended specifications that have been developed to provide guid-
ance for safe storage and handling of jet fuel at commercial airports. While these recommen-
dations are not mandatory, they are very closely followed by all major airlines and airports in
the United States.
FAA policies: What airport design specifications and standards should be consulted when
planning siting and design of an alternative jet fuel processing plant?
Alternative jet fuel processing facilities located on the airport are subject to the same FAA
policies and regulations governing any other type of airport facility. In particular, on-airport
processing plants and storage facilities must comply with FAA AC 5300-13, Airport Design,
which forbids locating fuel storage facilities in the runway protection zones (RPZs). In addi-
tion, AC 5300-13 does not allow objects not essential to air navigation or ground maneuver-
ing purposes, such as fuel processing facilities, in the runway object free areas (ROFAs), run-
way safety area (RSAs), or obstacle free zones. Also of importance is 14 CFR Part 77,
Objections Affecting Navigable Airspace, which establishes standards for determining obstruc-
tions to air navigation by defining criteria for imaginary surfaces that must not be pierced by
any structure, including fuel production and storage facilities. Another consideration is that
the proposed project must be shown on the airport layout plan (ALP), as indicated in FAA
Order 5190-6b.
Near-airport and off-airport alternative jet fuel processing plants located outside of the airport
limits are not subject to the FAA policies and regulations governing on-airport facilities; however,
near-airport and off-airport facilities must still comply with 14 CFR Part 77. For example, objects
such as light poles, trees, construction cranes, and even tall buildings (sometimes miles away from
the airport) can be in violation of 14 CFR Part 77 and would, therefore, present a potential hazard
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32 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting
to aircraft operating in the area. Form 7460-1, Notice of Proposed Construction or Alteration,
needs to be completed and filed with the FAA prior to construction for an airspace analysis and
determination for either on-airport, near-airport, or off-airport projects.
FAA policies: Are alternative jet fuel projects at airports eligible for Airport Improvement
Program funding?
Costs associated with alternative jet fuel production are not Airport Improvement Program
(AIP) eligible. Refining and manufacturing of aviation fuels, whether from conventional or
alternative feedstocks, are not aeronautical activities. The handling, storing, and delivery of
jet fuels to an airplane may be considered aeronautical activity as long as 100% of the fuel is
delivered to aircraft on the airport and not distributed elsewhere. Therefore, on-airport fuel
storage is eligible but only using non-primary airport entitlements. Furthermore, since the
production of alternative fuels is not an aeronautical activity, leases will need to be at fair
market value.
For more information, airports are encouraged to contact their local FAA office. Contact
information for FAA regional offices is available at http://www.faa.gov/about/office_org/
headquarters_offices/arp/regional_offices/.
FAA policies: What items must be considered to ensure compatible planning with existing
and future surroundings?
Being a good neighbor is often a principle that airports adopt since it can enable a mutually
beneficial relationship between airport operators and surrounding developments and avoids
potentially costly litigation. In order to avoid conflict with airport surroundings, land-use zoning
must be done carefully in the areas near an airport.
In general, zoning rules and regulations vary considerably from one jurisdiction to another
and it is not practical to summarize them in this document. Airports should consult ACRP
Report 27: Enhancing Airport Land Use Compatibility (Ward et al. 2010) for a deeper discussion
of this topic. Nevertheless, there are a few general observations that can help airports evaluate
alternative fuel projects with respect to zoning:
· Obstacles to air navigation: The FAA requires that there be no object, man-made or natural
outgrowth, 200 ft from the ground level of the airport and within a 3-nautical-mile radius of
the established reference point of the airport. Other requirements are listed in Federal Aviation
Regulations (FAR) Part 77.
· Noise assessment: If construction of alternative jet fuel facilities requires modifications to
existing airspace procedures, the FAA and airport would need to comply with NEPA require-
ments. This may require a proper environmental impact statement (EIS) before the FAA can
approve route changes when there is a significant noise impact on the affected population.
Noise impacts from the alternative jet fuel facility on the immediate surroundings should also
be investigated for potential permitting review requirements.
· Agricultural land near airports: The FAA recommends against using airport property for
agricultural production because agricultural crops can attract wildlife (FAA 1997b). If the
airport requires agricultural crops as a means to produce income necessary for the viability
of the airport, it needs to follow the crop distance guidelines established in AC 150/5300-13,
Appendix 17. Airports should be advised that the FAA may require a wildlife hazard assess-
ment (WHA) or a wildlife hazard management plan (WHMP) when specific triggering events
occur on or near an airport, as specified in 14 CFR Part 139, Certification of Airports. Such
events include an aircraft striking wildlife, an aircraft engine ingesting wildlife, or observing
wildlife of a size or in numbers capable of causing an aircraft strike or engine ingestion. The
WHA plan must be conducted by biologists with appropriate training and education as spec-
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How Can Alternative Jet Fuels Be Integrated into the Airport Setting? 33
ified in AC 150/5200-36. Agricultural land use is compatible with airport operations from a
noise sensitivity perspective (FAA 2001).
Environmental reviews: What environmental review requirements should be considered?
Jurisdictions at the federal, state, and local levels require permits for those activities or facilities
they view as affecting the environment, safety, or equity of the surrounding population. Alterna-
tive jet fuel plants affect each of these three components. In general terms, the main categories of
interest in the environmental review and permitting process tend to be the following:
· Water quality, including environmental impact on drinking water, groundwater, wastewater,
and surface waters, including storm water, coastal areas, wetlands, and floodplains.
· Air quality, including environmental impact of gaseous and other emissions.
· Impacts to endangered species or historic, coastal, or other environmental resources by facility
construction, operation, maintenance, or access.
· Land quality, including solid waste disposal, hazardous waste handling and disposal, and spill
prevention, reporting, and cleanup.
· Land-use planning and zoning, including impacts to shared infrastructure such as roads and
railways.
Environmental reviews: What guidance is there to meet the environmental permitting
requirements?
At the federal level, alternative jet fuel projects need to comply with NEPA and applicable laws
protecting sensitive environmental resources. NEPA outlines a process by which agencies are
required to determine if their proposed actions have significant environmental effects. Depending
on the severity of the environmental effects, a categorical exclusion (CE), environmental assess-
ment (EA), or EIS may be required (see FAA Order 1050.1E for more information). In particu-
lar, the environmental issues addressed in the Environmental Desk Reference for Airport Actions
(FAA 2007) or Appendix A of Order 1050.1E should be investigated during the NEPA process.
This must occur before the FAA can make a decision on approving an alternative jet fuel facility.
For alternative jet fuel projects on the airport, airports should refer to FAA Order 1050.1E,
which is the FAA's umbrella guidance for NEPA compliance. Installation of on-airport fuel facil-
ities requires the FAA to issue an unconditional approval to an airport layout plan. This requires
the FAA to complete its environmental analyses under NEPA and other laws, such as special pur-
pose laws, protecting sensitive species (see the Desk Reference for Airport Actions for more infor-
mation). Other actions of the FAA that may be applicable to alternative jet fuel production include
federal funding and release of federal lands.
Additional reviews related to Clean Air Act statutory programs, such as New Source Review
and New Source Performance Standards, may be required. These address construction permits
or installation of emission control technologies for new facilities or modification of existing
major sources that might result from locating an alternative jet fuel facility at or near an airport.
Note that these reviews are not limited to non-attainment areas. A Clean Water Act permit may
also be required.
At the state and local level, there is a high degree of variation in terms of environmental
review and permitting requirements and regulations. They often vary from one jurisdiction
to the next. Many states are developing review processes and integrated guidance materials
on environmental review and permitting activities relative to infrastructure that may be
applicable to alternative jet fuel projects (see Section 6.2). Furthermore, the EPA maintains
a database of state-specific regulatory information at http://www.epa.gov/lawsregs/states/
index.html#state.
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34 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting
How can the FAA's regulatory and environmental review considerations of an alternative jet
fuel project be evaluated?
To evaluate the regulatory aspects of an alternative jet fuel project, use "Worksheet 2: Regula-
tory Considerations," provided in Section 5.2.2. The following evaluation guide is recommended
for grading the different options after Table 9 in the worksheet has been completed:
· Green: The project can meet all regulations and other considerations. (Only boxes in "Meets
Regulation/Consideration" column are checked.)
· Yellow: The project is likely to meet all regulations and other considerations with some extra
effort. (Most boxes in "Meets Regulation/Consideration" column and only a few in "Likely to
Meet Regulation/Consideration" column are checked.)
· Red: The project cannot meet all regulatory and other considerations. (One or more boxes in
"Does Not Meet Regulation/Consideration" column are checked.)
After completing the grading, fill in the appropriate circle in the "Green," "Yellow," or "Red"
column in the "FAA regulations and environmental review" row of "Worksheet 6: Evaluation
Summary" in Section 5.2.6.
Energy policy: What governmental and nongovernmental entities have stated their support
for alternative jet fuel projects?
Support for alternative jet fuel projects comes from various entities and policies, including the
federal government and nongovernmental organizations (NGOs). This section summarizes some
of the most visible entities and policies and indicates how they may be helpful to alternative jet
fuel projects:
· The current administration in the White House: The White House has a policy framework
that supports both biofuel production and the allocation of funds to aviation fuel sources.
These policies include a commitment made in 2009 by the USDA to allocate funds to biofuels
development (USDA 2009) and the 2010 Biofuels Interagency Working Group report high-
lighting aviation fuel deployment. This report calls for using pre-established market outlets
and customer purchase commitments to stimulate production of feedstocks and biofuels
(EPA 2010e). These policy support statements culminated in August 2011 with a White House
initiative that provides a $510 million, 3-year commitment by the Navy, USDA, and DOE of
multiple alternative fuel projects (The White House 2011). White House policy statements are
of significance to airports since they can help airport leadership establish priorities and identify
agencies tasked by the White House to implement alternative fuel support programs.
· FAA: The FAA Office of Environment and Energy sets policy and offers programs to monetize
the benefits of using alternative fuels. Relevant initiatives sponsored by this office include:
NextGen Environmental Working Group: This group, part of the Joint Program Develop-
ment Office (JPDO), sets goals for carbon and particle emission reductions associated with
aviation traffic growth projections enabled by NextGen. One important use of alternative
fuels is to offset carbon growth associated with this traffic growth.
Partnership for Air Transportation Noise and Emission Reduction (PARTNER) Proj-
ect 20--Emissions Characteristics of Alternative Aviation Fuels: This project character-
izes particle emission measurements for a series of alternative fuels (PARTNER 2010a).
Airports can use Project 20's measured outcomes to establish actual particle outcomes for
specific process outputs under consideration.
PARTNER Project 27--Environmental Cost-Benefit Analysis of Ultra Low Sulfur Jet
Fuels: This project established the health effects of particles for use in conjunction with
the FAA's Aviation Portfolio Management Tool (APMT) suite (PARTNER 2010b). While
not an alternative fuel in itself, low-sulfur versions of conventional jet fuel are currently
under evaluation by FAA as a possible complement to alternative fuel options to contain
sulfur and related particle costs.
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How Can Alternative Jet Fuels Be Integrated into the Airport Setting? 35
PARTNER Project 28--Environmental Cost-Benefit Analysis of Alternative Jet Fuels: This
project quantifies aviation-specific GHG emission levels for a range of alternative fuel
options that may be proposed for adoption by airports and their stakeholders (PARTNER
2010c). Airports can use these results in conjunction with Section 2.4 to establish the actual
GHG benefits for specific feedstocks and processes.
The FAA has other programs that may be of interest for alternative aviation fuel projects.
These include:
Voluntary Airport Low Emissions (VALE) Program: VALE was established in 2004 to help
commercial service airports in designated air-quality non-attainment and maintenance
areas reduce airport ground emissions (FAA 2011b). VALE allows airport sponsors to use
the AIP and passenger facility charges (PFCs) to finance low-emission vehicles and certain
infrastructure projects. However, projects that use alternative jet fuels are not eligible for
funding under VALE. Participation in the program could still be valuable for airport spon-
sors as a means to gain valuable experience structuring projects that reduce air emissions
using other clean-energy fuels.
Sustainable Master Plan Pilot Program: This program was recently introduced by the FAA
and is evaluating ways to make sustainability a core objective at every airport (FAA 2011a).
It is funding long-range planning documents at 10 airports around the country. These doc-
uments, called Sustainable Master Plans and Sustainable Management Plans, will include
initiatives for reducing environmental impacts, achieving economic benefits, and increas-
ing airport integration with local communities. The program is projected to end in late
2012. This program may provide valuable information to airports interested in integrating
alternative jet fuel projects into their sustainability initiatives.
· Public/private partnerships and coalitions: Several organizations focused on the development
and deployment of alternative jet fuels have been formed over the past few years. These include:
Commercial Aviation Alternative Fuels Initiative: CAAFI is a coalition of government and
private-sector organizations, including the FAA Office of Environment and Energy; Aero-
space Industry Association (AIA), representing manufacturers; ATA, representing airlines;
and Airport Council InternationalNorth America (ACINA), representing airports (CAAFI
2010). CAAFI's 350 members represent nearly 250 separate entities, including some 17 U.S.
government agencies.
CAAFI may be contacted through its public website, www.caafi.org. Airport personnel can
also join CAAFI for no membership charge and gain access to all documentation and guid-
ance on its password-protected site.
ATA/Defense Logistics Agency Alliance: In March 2010, the ATA signed an agreement with
the Defense Logistics Agency (DLA, formerly the Defense Energy Support Center or DESC)
to pursue joint policies for the purchase of alternative fuels. The alliance seeks to align pur-
chasing policies, promote deployment, and pursue common economic policies (ATA
2010b). The alliance covers over 90% of all jet fuel purchased in the United States. It main-
tains teams on deployment, contracting, and the environment, and will work with potential
project developers to establish means of best accessing those markets.
Farm to Fly: The Farm to Fly coalition of interest between U.S. Department of Agriculture,
the ATA, and Boeing was formed in July 2010 (ATA 2010a). The coalition brings together
agriculture, energy, and aviation interests to support deployment activity, initially working
on bottom-up models for developing fuel supplies for aviation regions of the United States.
Other regional coalitions: There are regional initiatives focused on partnerships for the de-
velopment of alternative fuel projects in specific geographic areas. Examples include the
Georgia Center of Innovation for Energy (GCI 2011), the Hawaii Renewable Energy
Alliance (HREA 2011), Clean Fuels Ohio (CFO 2011), and the Sustainable Aviation Fuels
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36 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting
Northwest (SAFN) in the U.S. Pacific Northwest region (SAFNW 2011a). SAFN just pub-
lished a detailed report analyzing and evaluating the potential for alternative jet fuel
production in their region (SAFNW 2011b).
· Aviation-related nongovernmental organizations: The entities listed in the following may
help airports in the development and evaluation of alternative jet fuel projects by sharing best
practices, case studies, and other expertise.
International Air Transport Association and its stated industry goal of carbon neutral growth
by 2020 (IATA 2010).
Air Transport Association and its policy on alternative fuels (ATA 2010c).
Airport Council InternationalNorth America (ACINA) and its sustainability and business
policies (ACINA 2010).
Sustainable Aviation Fuel Users Group and its policies (SAFUG 2011).
Non-aviation-related nongovernmental organizations: There are nongovernmental organi-
zations not directly associated with aviation that have participated in alternative jet fuel
forums and are aware of the development of alternative jet fuel. Even though their policies are
not necessarily focused exclusively on aviation alternative fuels, they offer different perspectives
that may be important to consider when evaluating projects. These entities include:
Roundtable on Sustainable Biofuels (RSB) and its best practices (RSB 2010).
Environmental NGOs: Several environmental NGOs, such as the National Resources
Defense Council and the World Wildlife Federation, have participated in alternative jet fuel
forums at the request of CAAFI in the United States and the Sustainable Way for Alterna-
tive Fuel and Energy in Aviation (SWAFEA) in Europe.
Energy policy: What programs exist to fund studies and other nonrecurring investments in
alternative jet fuels?
Readers should consult with CAAFI to determine which of the programs presented in the fol-
lowing can be useful to identify and support potential alternative jet fuel projects at their facilities.
The following programs may exist at the federal, state, or local levels:
· Biomass Crop Assistance Program (BCAP) associated with the 2008 USDA Budget Autho-
rization section 9000 for renewable energy (USDA 2010c).
· Value-added grants and state enterprise grants for rural renewable energy project evaluation
and development (USDA 2010p, USDA 2010m). The execution of this type of projects needs
to be submitted for funding in many cases through agricultural institutions. One example of
this process is afforded by a proposal made via the Soy Bean Growers Association in Ohio
(OHSOY 2010) for a brownfield plant conversion to produce alternative jet fuel.
· Military Title III programs that can enable initial plant construction for national defense
priorities (Finnessy 2006).
· The August 2011 three agency announcement to support the development of advanced bio-
fuels is supported by a $510 million commitment (The White House 2011). The rules con-
cerning how these funds will be used have not been finalized as of October 2011, but it is
expected that this program will be an important source of funding for alternative aviation fuel
projects over the next 3 years.
Energy policy: What programs exist that may allow recurring support for alternative jet
fuel projects?
The following policies may take a variety of forms, including tax incentives, insurance for
crops, and tax credits for alternative jet fuels. The details of these policies may still have to be
refined, so airports are encouraged to contact CAAFI for guidance. These programs may exist at
the federal, state, or local levels:
